
R vs Sang Case Summary
Facts:
- Defendants (Sang and others) accused of conspiring to import and supply cannabis.
- Undercover police officer infiltrated the group.
- Defendants argued entrapment.
Issues:
1. Whether entrapment is a valid defence in English law.
2. Admissibility of evidence obtained through undercover operations.
Held:
1. Entrapment is not a defence in English law.
2. Evidence obtained through undercover operations is admissible, but subject to guidelines.
Guidelines:
1. Undercover officers must not instigate or encourage crime.
2. The officer’s role should be passive, not active.
3. Evidence obtained through entrapment may be excluded.
Rationale:
- Entrapment is not recognized as a defence to prevent abuse of process.
- Undercover operations legitimate investigative tool, but require careful management.
Impact:
- Established guidelines for undercover operations in the UK.
- Influenced the development of entrapment law in commonwealth jurisdictions.
Key Points:
1. Entrapment not a defence in English law.
2. Undercover operations require careful management.
3. Evidence obtained through entrapment may be excluded.
~ Maihar Sundaram Singh ♤
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